Kaplan Kirsch
04 November 2025
On November 4, 2025, the federal district court in Rhode Island issued a decision with nationwide implications for all recipients of U.S. Department of Transportation (DOT) grants.
The district court concluded that the “immigration enforcement conditions” imposed earlier this year through DOT grant agreements are unlawful.
The court vacated (i.e., invalidated) those grant conditions in all DOT grants, which goes beyond the more limited preliminary injunction the court had issued earlier this year. The decision affects all FAA, FTA, FRA, FHWA, and other DOT grants.
Further appeals are possible, so grant recipients are encouraged to track this case closely and await further guidance from their agency contacts on how DOT will comply...
If you have questions, contact Tracy Davis, Peter Kirsch or Steve Osit for questions about airport programs, and Allison Ishihara Fultz, Ayelet Hirschkorn, Subash Iyer, or John Putnam for questions about transit programs.
